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ANDREW WEISSMANN
Chief
ALBERT B. STIEGLITZ, JR
Assistant Chief
MELISSA AOYAGI
Trial Attomey
Criminal Division, Fraud Section
United States Department of Justice
1400 New York Avenue, NW
Washington, DC 20530
(202) 514-4313
DANIEL G. BOGDEN
United States Attomey
District of Nevada
STEVEN W. MYHRE
First Assistant United States Attorney
District of Nevada
333 Las Vegas Blvd., South, Suite 5000
Las Vegas, NV 89131
(702) 388-6298
FILED. RECEVED
ENTERED, SERVED ON
: (COUNSEL7PARTIES OF RECORD
JUL - 8 205
"CLERK Us DISTRICT COURT
py, _DStR OF NEVADA
DEPUTY
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
UNITED STATES OF AMERICA,
Plaintiff,
EDWIN FUJINAGA,
JUNZO SUZUKI, and
PAUL SUZUKI,
Defendants.
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CRIMINAL INDICTMENT
aso ALL
VIOLATIONS:
Title 18, United States Code, Section 1341—
Mail Fraud (Counts One through Eight) (as to
all defendants);
Title 18, United States Code, Section 1343—
Wire Fraud (Counts Nine through Seventeen)
(as to all defendants);
Title 18, United States Code, Section 1957—
Engaging in Money Transactions in Property
Derived from Specified Unlawful Activity
(Counts Bighteen through Twenty) (as to
defendant FUIINAGA);
Title 18, United States Code, Section 2—
Aiding and Abetting (Counts One through
‘Twenty as to defendant FUJINAGA, Counis
One through Seventeen as to defendants
JUNZO SUZUKI and PAUL SUZUKI)13
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‘The Grand Jury Charges that at all times relevant to the Indictment:
BACKGROUND
1. Defendant Edwin FUSINAGA was a United States citizen, residing in Las Vegas,
|Nevada.
4, Defendant Junzo SUZUKI (“J. SUZUKI") was a Japanese citizen, residing in
Tokyo, Japan.
3, Defendant Paul SUZUKI (“P. SUZUKI") was a Japanese and United States
citizen, residing in Tokyo, Japan.
4, MRI International Inc. (“MRI”) was a Nevada Limited Liability Corporation
located and operated in Las Vegas, Nevada. Defendant FUJINAGA owned and controlled MRI
as its President and CEO. MRI operated a Service Center located in Tokyo, Japan. Defendant
SUZUKI was at various times MRI’s Executive Vice President (Asia Pacific), and Defendant
P. SUZUKI was at various times General Manager of MRI’s Japan operations.
‘THE SCHEME AND ARTIFICE TO DEFRAUD
5. From at least 2009 and continuing until at least in or about April 2013,
FUJINAGA, J. SUZUKI and P. SUZUKI, and others known and unknown to the Grand Jury,
aided and abetted by each other, made, and caused to be made, numerous material
misrepresentations and omissions designed to fraudulently induce investors to transmit money fo
MRI.
6. As part of the scheme and artifice, the defendants represented, among other
things, that MRI was engaged in the business of purchasing medical accounts receivable10
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MARS"), that is, debts owed by recipients of medical services or products to the individuals or
entities that provided those services. MRI purported to purchase the accounts from providers at &
discounted rate and then collect on the accounts from the patients owing money. MRI's profit
from this activity, according to the defendants, was generated from the difference between the
price at which MRI purchased the MARS and the amount MRI collected on them due to MRI’s
purportedly superior collections capability.
7. Asa further part of the scheme and artifice, the defendants, and others working
with them, solicited investments in MRI by offering Certificates of Investment (hereinafter
“